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    PRIVACY — Privacy and Data Processing Policy

    Version: 2 November 2025

    Who is the data controller: International Legal Initiative Genève (IDE/TVA: CHE‑329.024.359), Place de Longemalle 1, c/o MN & Associés SA, 1204 Genève, Switzerland.

    Contacts: costbackkz@gmail.comcontact form • +7 778 997‑84‑26

    This Policy is prepared in accordance with the nFADP/LPD (Switzerland, effective 01.09.2023) and takes into account the GDPR for users in the EU/EEA.

    Note on cross‑border transfers: The European Commission recognizes the adequacy of data protection in Switzerland (Art. 45 GDPR) — data may be transferred from the EU to Switzerland without additional safeguards.

    1. What data we collect

    1.1. Donor data

    Name, e‑mail, amount/currency, frequency, country, donor's message; for corporate sponsors — legal entity/position; technical identifiers of the transaction/account.

    1.2. Payment data

    Card details and authentication are processed by the payment provider (e.g., Stripe) on its infrastructure; we receive only tokens/identifiers/statuses and do not store card numbers.

    1.3. Communications

    Correspondence, submissions (including the contact form/demo).

    1.4. Technical data

    IP address, user agent, basic cookies/pixels (strictly necessary; analytics only with consent).

    1.5. Optional (demo/forms)

    A brief description of your case/question (please do not provide sensitive data unless required).

    2. Purposes and legal bases of processing

    • Donations and record‑keeping (acceptance, confirmations, reconciliation, reporting): performance of a contract/legitimate interests/legal obligations.
    • Communications (responses to inquiries; project news — only with opt‑in): consent/legitimate interests.
    • Security and anti‑fraud (sanctions/risk checks by the payment provider, abuse prevention): legitimate interests/legal obligations.
    • Compliance with law (KYC/sanctions where necessary; accounting and tax obligations): legal obligations.

    For users in the EU/EEA, the legal bases under Art. 6 GDPR apply (contract/LI/legal obligations/consent). For users in Switzerland — the nFADP/LPD and implementing ordinances (FDPO).

    3. Cookies and analytics

    We use strictly necessary cookies (session, security, anti‑bot). Analytics cookies are used only with your consent. For the EU/EEA, prior‑consent rules apply.

    4. Data retention

    • Finance/accounting for donations: at least 10 years (Art. 958f CO/OR; the period is calculated from the end of the financial year).
    • Subscriptions/newsletters: as long as the subscription remains active or until you unsubscribe.
    • Security/access logs: typically up to 12 months (longer where there is an incident/legal necessity).
    • Demo/contact requests: up to 24 months or upon your deletion request where no legal retention duty applies.

    5. Recipients and processors

    We do not sell personal data. Data may be processed by the following categories of recipients (under DPAs and appropriate security measures):

    Payment providers

    Stripe Payments Europe — acquiring/3‑D Secure/anti‑fraud.

    Hosting / IT infrastructure

    Replit, Inc. (USA) — website hosting and application runtime. Processing is governed by Replit's Data Processing Addendum (DPA). Replit maintains a public list of its subprocessors (including Google and Microsoft Azure for cloud infrastructure). Where personal data is transferred to the United States, we rely on the EU Standard Contractual Clauses (SCCs) (and, where relevant, the UK Addendum/Swiss Addendum) together with appropriate supplementary measures.

    E-mail / transactional messages / newsletters

    Google (Gmail/Workspace) — we currently use the mailbox costbackkz@gmail.com for incoming and outgoing communications. Where Google Workspace accounts are used under a Data Processing Amendment, Google acts as our processor; where consumer Gmail is used, Google may act as an independent controller for certain processing under its Privacy Policy. Data may be processed in the EU (Google Ireland Ltd.) and the United States (Google LLC). International transfers are safeguarded by the EU Standard Contractual Clauses (and, where applicable, the UK Addendum/Swiss Addendum and the EU-US Data Privacy Framework).

    6. International transfers

    Core infrastructure is located in the EU/Switzerland. If a given provider processes data outside the EU/CH, we apply legal mechanisms: SCCs (EU), adequacy (where available), and supplementary safeguards. For flows EU → Switzerland, the adequacy decision applies.

    7. Your rights

    Within the limits of applicable law, you may request: access, rectification, erasure, restriction, objection (including to analytics/marketing), portability, and withdrawal of consent.

    Please send requests to costbackkz@gmail.com (or via the "Privacy / GDPR Request" form). We respond within a reasonable time (for the EU — typically within 30 days).

    Supervisory authorities:

    • Switzerland — FDPIC, Feldeggweg 1, CH‑3003 Bern.
    • EU/EEA — your local data protection authority.

    8. Security

    We implement technical and organizational measures: encryption in transit and at rest, access control (RBAC/MFA), logging, backups, vulnerability and incident management, and data minimization; measures are adjusted based on risks under the FDPO. Payment data is processed by the provider on its secure infrastructure; we do not store full card details.

    9. Children

    The website and donations are not intended for individuals under 18; we do not knowingly collect such data.

    10. Automated decisions

    We do not make decisions with legal effects based solely on automated processing without human involvement. Anti‑fraud assessments by the payment provider are carried out with human oversight/appeal.

    11. Sanctions/KYC/AML inquiries

    Where risks are indicated, we may request supporting documents (country of residence, source of funds, etc.), and a payment may be suspended/returned in accordance with the law and payment system rules. (This section does not render the Organization a financial intermediary within the meaning of the Swiss AMLA.)

    12. Related documents

    Please also review our Terms of Use and Disclaimer for important information about using our website and services.

    13. Changes to this Policy

    We may update this Policy. Material changes will be announced on the website/by e‑mail. Continued use constitutes acceptance of the updated version.

    14. Privacy contacts

    Controller: International Legal Initiative Genève
    Address: Place de Longemalle 1, c/o MN & Associés SA, 1204 Genève, Switzerland
    E‑mail: costbackkz@gmail.com